A$,$ B$,$ & C together form a new corporation. A & B each contribute property in exchange for stock. A & B each receive $50$ shares of stock for their property. One month later, C contributes other property to the corporation in exchange for $50$ shares of the corporation's stock. Which transactions, if any, will qualify under IRC $5351?$

$$A$.$ Both transactions will qualify under IRC $5351$ if they are part of the same plan of corporate formation.

$$B$.$ Neither transaction qualifies under IRC $5351$ because it violates the step$-$transaction doctrine.

$$C$.$ Only the first transaction qualifies under IRC $5351$ because the second transaction does not satisfy the control requirement because C alone only owns $33\mathrm{.}33\%$ of the stock.

$$D$.$ Only the second transaction qualifies because the first transaction does not satisfy the control requirement because A & B only own two thirds of the total stock. The control requirement is not met until C is issued his stock.